QUALITY MANAGEMENT STANDARDS:
Your Final Call to Action Before December 15, 2025
By Peter Zender & NCACPA's A&A Resource Group
If December 15, 2025, still feels comfortably distant, remember that “someday” on the calendar has a habit of turning into “today” often faster than we can believe. The AICPA’s quality management suite including, SQMS 1, SQMS 2, SQMS 3, SAS 146, SSARS 26, and SSAE 23 will be fully live on that date, and firms that audit, review, or compile must have their systems designed and implemented by then.
Why a New Playbook?
The last major overhaul of quality control standards was in 2006; since then, advances in technology, shifts in firm operations, evolving regulatory expectations, and peer-review findings have renewed the focus on quality management. Enter the new standards: they align more closely with international rules, clearly designate responsibility for quality, and push firms toward a risk-based, firm-specific approach instead of a one-size-fits-all checklist.
Meet the Eight-Component System of Quality Management (SQM):
Under SQMS 1, every firm must design, implement, and operate a SQM built around eight inter-related components:
Firm risk assessment process
Relevant ethical requirements
Governance and leadership
Acceptance & continuance of clients and engagements
Engagement performance
Resources (human, technological, intellectual, and service-provider)
Information & communication
Monitoring & remediation
Under the new risk assessment methodology, each component carries its own quality objectives, risks, and tailored responses; add the expanded documentation requirements, and you end up with a living document that accurately reflects your firm’s quality-management reality.
Categories of Resources
- Talent
- Technology
- Intellectual Property
- External Service Providers
SIGNIFICANT UPDATES:
Resources, Monitoring, and Remediation
Resources now span four categories: talent, technology, intellectual property (templates and methodologies), and external service providers. Firms must demonstrate they recruit for quality, provide ongoing training, and rigorously vet external vendors and new systems or platforms for impacts on engagement quality.
Monitoring and remediation get an upgrade as well. When a quality deficiency appears, conduct a root-cause analysis, much like tracing an audit error or control deficiency, to gauge firm-wide impact and design fixes that address the problem at its source. Begin testing your new SQM in early 2026; after that, those responsible must evaluate it at least annually. The first formal evaluation and documented conclusion are due by December 15, 2026.
Implementation Countdown
2025 - By Dec 15: finish policies, train staff, document SQM, appoint monitoring lead.
2026 - Early 2026: run monitoring procedures; remediate promptly.
Free Tools to Assist Your Implementation
- AICPA Practice Aids - Interactive guides for sole practitioners or small/medium firms, plus an excel template with required quality risks and responses to jumpstart a firm’s documentation.
- NCACPA Resource Hub - state-society articles and webinars.
Act Now!
- Name those responsible for the quality management system. Designate and document who owns each SQM component and who will monitor.
- Assess your risks. Use available resources to map the required objectives and responses, and gather relevant organizational data to build a comprehensive risk profile and assessment.
- Clear communication. Make sure engagement partners and teams understand SAS 146/SSARS 26 changes and their role in the firm-wide approach to quality.
- Update policies and templates. Replace “quality control” references with “quality management,” add risk/objective mapping, and embed tech vetting checklists.
- Talk to your peer reviewer. A 30-minute call now to align on requirements can spare scramble or headache later.
Bottom Line
The new quality-management standards aren’t simply another compliance box; they’re a blueprint for sustainable, risk-focused audit quality. Many firms already have strong quality controls, processes, and policies in place; the task now is to document them and ensure they align with the new requirements. December 15, 2025, will arrive whether your SQM is battle-ready or barely drafted, so start documenting today before time runs out.
Explore More!
NCACPA has developed a special resource page to house valuable content created by our A&A Resource Group on SQMS. In addition to their recent articles, we've also included relevant learning opportunities to support your professional growth. Visit to explore these resources.